There are many issues which could be addressed in order to improve the European privacy and data protection framework. As it has my special concern I have today on my behalf taken the opportunity to forward the following recommandation to the EU Directorate Justice, Freedom and Security.
You may approach data protection/privacy in four different ways:
In my opinion there is a strong need for a comprehensive Pan-European academic as well as industrial learning and education program in privacy and data protection. Therefore I would like to recommend a feasibility study regarding the establishment of an European privacy learning and education programme at EU.
In order to strengthen awareness and accountability I would like also to recommend a new rule that every public or private entity with at least 50 employees should appoint a data protection/privacy officer who should attend a certified data protection/privacy course.
I have taken the liberty to mention that The European Privacy Institute would be able to contribute with exceptional knowledge and expertise taking into account that the scientific advisory board has representation in all European countries.
About the joint reaction of the Article 29 Working Party (WP29) and the Working Party on Police and Justice (WPPJ) to this consultation, please check The Future of Privacy adopted 1th December 2009.